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Suicide Exclusions: N.D. Ind.

In a morbidly fascinating case out of Indiana, the court wrestles with the Defendant's denial of life insurance benefits as a result of the policy's suicide exclusion. As the court notes:

What appears to be a fairly straightforward case is complicated by the timeline of events. Mr. Cole originally began paying into a policy offered by a different insurance company on January 1, 2014. That policy did not contain a suicide exclusion and he paid into that policy until January 1, 2016. Sometime prior to that date, Mr. Cole’s employer contracted with a new insurance company to provide this particular employee benefit effective January 1, 2016. The policy of the new company, Defendant American Heritage Life Insurance Company, contained a suicide exclusion limiting the benefit amount to the premiums paid if the insured committed suicide within 2 years of the certification date. The new policy went into effect on January 1, 2016, one day before Mr. Cole took his own life.

The Plaintiff argues that the policies should be read together, and any ambiguities construed against the Defendant. The Defendant proffers that they should not be held accountable for another insurer's policy language when it's clearly contained a suicide exclusion. The court reasoned as follows:

This case starts and ends with the Suicide Exclusion. The existence and terms of the Suicide Exclusion are undisputed. The question before me is what is the proper commencement date of the Suicide Exclusion. The Coles argue that the Suicide Exclusion has been satisfied by virtue of Mr. Cole’s prior coverage under the Lincoln National Group Policy. Specifically, they argue that the Lincoln National Group Policy, under which Mr. Cole was covered for two years, was merely converted to the American Heritage Group Policy, which covered Mr. Cole for one additional day prior to his death, meaning that Mr. Cole met the two year requirement of the American Heritage Suicide Exclusion by one day, entitling the Coles to benefits.

Ultimately, the court found for the Defendants.

Accordingly, because the effective date of the American Heritage Group Policy was January 1, 2016 and Mr. Cole took his life on January 2, 2016, the Coles’ claim for benefits under the American Heritage Group Policy was properly denied pursuant to the Suicide Exclusion. As such, American Heritage’s motion for summary judgment will be granted and the Coles’ motion for partial summary judgment will be denied.